Human Resources
Aon Hewitt Submits Comments to PBGC on Proposed Submission of Information Collection on Payment of Premiums

Aon Hewitt Submits Comments to PBGC on Proposed Submission of Information Collection on Payment of Premiums


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On November 21, 2014, Aon Hewitt submitted comments to the Pension Benefit Guaranty Corporation (PBGC) on the proposed additional information intended to be collected by the PBGC via the annual premium filing process. The PBGC published the notice of intention to request Office of Management and Budget (OMB) approval of the revised collection of information in the Federal Register on September 23, 2014.

The PBGC proposes to revise its premium filing procedures and instructions beginning with the 2015 premium payment year to require “reporting of certain undertakings to cash out or annuitize benefits for a specified group of former employees.” In comments to the PBGC, Aon Hewitt stated that the PBGC should not collect this information through premium filings for several reasons:

  • Information reporting should be governed by ERISA Section 4043;
  • Premium filing information is publicly available;
  • Information is not needed for premium purposes; and
  • Collection may be a burden for small plans or small offers.

Aon Hewitt also recommended that if the PBGC proceeds with the proposed information collection, that the PBGC change or clarify its instructions regarding the information collected.

The Aon Hewitt comment letter was authored by Monica Gajdel and Eric Keener (Retirement).

Aon Hewitt Submits Comments to PBGC on Proposed Submission of Information Collection on Payment of Premiums